SHERMAN OAKS, CA – Have you noticed an uptick in revalidation issues lately? With additional contractors and site inspectors, many HME providers are experiencing the revalidation site inspector knocking at their door unannounced.
Site Inspector’s Role
During a site visit, according to the National Provider Enrollment (NPE) Contractors, “site visits are a crucial component of the enrollment process and are used to determine a supplier’s compliance with the DMEPOS supplier standards and other Medicare regulations.” Simply stated, the site inspector’s main job is to ensure that everything you listed on your CMS-855S application matches the information they receive during their site visit.
What To Expect
The inspector performing the site visits must have a photo ID and a CMS-issued signed authorization letter for the visit.
Specifically, the NPE (National Provider Enrollment) contractors emphasize a few select things to be mindful of:
- Hours of operation – Be certain to have your business hours posted. If, for some reason, you are temporarily closed, post a sign accordingly and notify the National Provider Enrollment Contractor. Best is to both notify them in writing and by speaking to a representative. Document all of this, of course.
- Products – Be sure to list the product categories you currently supply. If you add an item in a new category (e.g. you are now carrying continuous glucose monitors – [CGMs]), notify your accrediting body and Medicare (NPE).
- Ownership and management information – Ensure that you inform the National Provider Enrollment Contractor of any changes in management and owners. To be sure you notify Medicare of the right employees, according to the Program Integrity Manual (PIM), Chapter 10, “managing employees are general managers, business managers, administrators, directors, or other individuals who exercise operational or managerial control, or directly or indirectly conduct day-to-day operations, either under contract or through some other arrangement, whether or not the individual is a W–2 employee of the provider or supplier.” This should help you determine if you need to notify the contractors of a new employee or change of staff. Also, the emphasis should be on matching the information to what is on file with the contractor. Further, the accreditation agency should have the list of the same products you carry as the ones you listed on your application.
- Licensure and documentation – Maintain updated licensure information. An internal checklist that is updated regularly is recommended. While the NPE has a list of current licenses, do not rely solely on this as it is always subject to change.
- Protocols – Ensure you have proper documentation and protocols (e.g. supplier standard adherence) to support compliance.
Noncompliant?
If your company is flagged during a visit, you may find your NPI (National Provider Identifier) may be at risk is in jeopardy or revoked, call Medicare to determine what rule you have violated and how to remedy it. Turn this matter over to your compliance officer/team and/or management. Depending on the severity of the violation, you may only have to submit a Corrective Action Plan (CAP). To stay abreast of these matters, use dedicated compliance staff. You may also work with outsourced compliance, HME industry attorneys and consultants dedicated to these matters.
Proactive Approach
The bottom line is that as an HME supplier work proactively rather than responding to a surprise visit from a contractor. Stay engaged by participating in industry committees and associations, subscribe to regulatory newsletter and stay ahead of the curve.
Specifically, stay updated with announcements and newsletters from:
NPE East/West
State and national HME associations
Industry publications
Your accrediting organization
NPWest Newsletter Article
Per the recent NPWest Newsletter article: “Please ensure these documents are readily available for the inspector.
- Ownership/Management – Listing of ALL owners/management to include names and titles
- Complaint log and resolution protocol
- Rent/Purchase option notification
- Proof of warranty coverage
- Contact information to beneficiaries at the time of delivery.”
Source: https://palmettogba.com/palmetto/npewest.nsf/DID/X352R90PQT#ls
Miriam Lieber is founder of California-based Lieber Consulting Associates.
